5GAA submitted comments to the National Highway Traffic Safety Administration
The 5G Automotive Association (5GAA) submitted comments to the National Highway Traffic Safety Administration (NHTSA) notice of proposed rulemaking (NPRM), "Federal Motor Vehicle Safety Standards; V2V Communications." The proposed rule is to mandate new light-duty vehicles to be equipped with dedicated short range communications (DSRC).
5GAA is a new global cross-industry association of automotive, technology and telecommunications companies and includes 42 members, of which 8 are founding members (AUDI AG, BMW Group, Daimler AG, Ericsson, Huawei, Intel, Nokia, Qualcomm). Our mission is to enable communications solutions that address society's connected mobility and road safety needs.
In our submission, 5GAA applauds the concept behind the rule, as V2V safety is important to our technology deployment mission. 5GAA urges NHTSA to not consider just the best technology of today, but also to consider the best technologies of tomorrow. Such an approach will promote innovation and competitive market-based outcomes, ensuring that American drivers and passengers benefit from the best and most advanced safety solutions available as technology evolves. Rigid technology mandates such as specifying DSRC, whether direct or de facto, freeze technology solutions to a past point in time. NS will significantly impede the innovation and evolution path for Vehicle-to-Vehicle (V2V) safety, and positions the US to lag behind the rest of the world in V2V communications specifically as well as V2X broadly. 5GAA elaborates on the following points:
Similar to DSRC, Cellular-V2X technology for V2V safety can transmit BSM in an ad hoc manner without cellular network coverage.
Cellular-V2X technology for V2V safety communications can operate without a SIM card and offers the tools to adopt, evolve or innovate any privacy-preserving security management system including SCRM.
Cellular-V2X technology for V2V safety benefits from a significantly larger link budget than DSRC (e.g., 8 dB at high speeds), corresponding to twice the range of DSRC and higher reliability.
Cellular-V2X technology for V2V safety can support up to 50 messages per second with less than 20 msec latency.
Cellular-V2X enables V2V, and for that matter Vehicle-to-Infrastructure (V2I), Vehicle-to-Pedestrian (V2P) and Vehicle-to-Network (V2N), safety applications to take advantage of the widespread cellular network coverage in the US.
5GAA notes also that the impending launch of 5G will only widen the performance gap between Cellular-V2X and DSRC.
5GAA believes that Rather than moving forward with the proposed regulation, NHTSA should instead undertake an updated, comprehensive technology neutral analysis of V2V solutions, including DSRC and Cellular-V2X, against the performance requirements in the NPRM. If this review indicates that regulatory action is necessary, the U.S. Department of Transportation should move forward with a technology neutral regulation that sets forth minimum V2V safety performance requirements only.
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